Opposition to Motion for Summary Disposition

[Carolynn Beck <carolynn.beck@gmail.com>]

Attachment: Draft_3.doc
Description: MS-Word document

Haytham,

Attached is my revised draft of the opposition. Regarding the request  
for extension of discovery - you only mentioned Trevor Clark's  
testimony on the phone earlier, so I assumed you had wanted me to take  
out the additional information I had put into the previous draft of  
the motion (regarding "Big Greg" and the management of Coogi and reps  
from the other vendors). So, in my argument for additional discovery,  
I only asked the judge to allow extension to enable us to depose  
Trevor Clark. Is this what you had meant earlier? I had wanted to make  
sure this won't narrow down our ability to depose other witnesses if  
necessary. I'm assuming you made this decision for strategic reasons  
but just wanted to make sure I understood you right earlier.

Please feel free to call me anytime tonight or tomorrow morning if you  
need me to revise this or put that section regarding the other witness  
depo's back in. I'll call you in the morning to make sure you got this  
and everything's good. Also, please let me know when you'll have a  
moment to discuss my next assignment. :-) Thanks Haytham!

Carolynn


Carolynn Beck
(202) 316-1367